This article discusses and analyses developments in relation to the reform of Australia's anti-deferral rules, in particular, the proposed rewrite of the controlled foreign company (CFC) rules, the repeal of the foreign investment fund (FIF) rules and the introduction of a modified distribution exemption (to replace section 23AJ of the Income Tax Assessment Act 1936).

Author profiles:

Cameron Blackwood ATI

Cameron Blackwood brings more than a decade of transactional tax expertise to his role as Director in Greenwoods & Herbert Smith Freehills’ Sydney office. He specialises in advising clients on the tax complexities of mergers, acquisitions and restructures, including cross-border issues and all aspects of employee share schemes; and regularly works in close collaboration with Herbert Smith Freehills. After joining the Greenwoods & Herbert Smith Freehills as a graduate in 2004, Cameron built his corporate experience advising companies and on a wide range of advisory and compliance matters, including a secondment with BHP Billiton. His industry knowledge is broad and includes the mining, real estate and financial services sectors. Current at 04 November 2016

Jane Michie CTA

Jane is an Executive Director at Macquarie Group in the Taxation Division. She specialises in income tax issues, particularly international tax and the taxation aspects of the financial services industry. Jane is heavily involved in the consultation process with Treasury on the proposed changes to the anti-deferral measures. Current at 10 November 2011

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